What is this project about?
G-M Pearson wishes to build and operate a thermal treatment plant to safely treat biomedical and other non-hazardous waste.
What is a thermal treatment plant?
At its core, a thermal treatment plant is an incinerator designed to safely treat solid waste through a high temperature controlled burn process, in which chemical and physical reactions convert combustible material into flue gas, and non-combustible material into ash.
Large solid residuals are captured as “bottom ash,” and are stored before being transported offsite for disposal. Small solid residuals are captured as “fly ash,” and are are stored before being transported offsite for disposal.
Flue gas is treated to remove any harmful chemicals before being discharged to the atmosphere through a stack. For some flue gas components, real-time monitoring equipment feeds information back to a process control unit that adjusts operating parameters for the incineration process.
We carefully monitor the quality of ash and flue gas to ensure the treatment process is operating as intended.
What makes for a good site location?
Site considerations fall into a number of categories. The first category is relatively straight forward to assess and includes: transportation cost to reach site from major centers in Alberta, access to water, sanitary waste system, gas, electricity and highway. The second category is more difficult to assess and includes: availability of local work force, maintenance services, and community infrastructure. Lastly, and most difficult to access is the community acceptance of site relative to surrounding land uses. Experience tells us this is the most significant factor in finding the right site. It requires an assessment of the surrounding communities perception of a suitable location, which is often different from what a scientific process would yield as a suitable location. As an example, in Europe these facilities are often incorporated into hospital utility plants and sit adjacent to residential areas and schools. A scientific approach approach supports this as a safe and suitable location. In North America, and specifically Alberta, the most peoples perception is this type of facility sits remote to populated areas. Thus finding a location that community perceives is sufficient distance from community but still provides access the first two categories of site location needs has become a challenge.
Are there any health risks associated with this project?
The proposed facility cannot be built without approval from the provincial regulators, Alberta Environment and Parks (AEP). Their approval is for construction, operation and reclamation.
Prior to receiving a permit, provincial regulators will review the design, along with the results of studies G-M Pearson will conduct to ensure the environment and public health are protected.
Once these studies are completed, and it is demonstrated the plant is safe to the community and environment, then a permit is issued by the province. The manufacturer of the equipment has successfully designed and built incinerators that meet requirements of operation in Alberta.
Will this project create job opportunities?
Yes, this facility will be operational 24/7 through the year, with generally a one-month shutdown each year for maintenance and upgrades.
We will be hiring general labourers as well as qualified operators. If available, we would also need access to services that may include hardware store products, welding, electrical, landscaping, restaurant and fuel services.
G-M Pearson recognizes the importance of employing people from within the community, training employees and interacting within the community in a transparent manner to provide confidence in the safe operation of the facility.
Will there be noise from the facility?
The facility will generate minimal noise. If you were on location, you may hear the fan running on the outside of the building.
How much traffic will there be?
We expect three semi trailers on average per day.
We can expect up to 20 passenger vehicles per day. This will include employees, contractors and delivery vehicles.
Are taxpayers’ dollars being spent on this project?
No, this project is being financed privately. No public dollars are involved.
As a private company, who is G-M Pearson accountable to?
G-M Pearson operates in a highly-regulated environment. We endeavor to follow all applicable rules and regulations and it is important to us to have a safe and healthy environment for all of our employees and neighbors.
We are accountable to many agencies, including:
- The municipality through their municipal development permit.
- The municipality through their direct control bylaw.
- Provincially by Alberta Environment and Parks. We will be required to have approval from the Alberta Environmental Protection and Enhancement Act (EPEA).
- Provincially by Occupational Health & Safety (OH&S).
- Provincially by the Workers’ Compensation Board (WCB).
We are committed to being a good neighbour and a responsible member of the community.
What are the environmental impacts associated with this facility?
As part of the provincial regulatory approval process required from the Alberta Environmental Protection and Enhancement Act (EPEA), G-M Pearson will conduct a number of assessments on the proposed site. These may include:
- Surface water and drainage studies
- Assessments on rare plants
- Assessments on wildlife in the area
- Air Quality
What specifically will be incinerated?
There will be a range of materials incinerated at the proposed facility, including:
- Biomedical waste
- Non-hazardous waste
- Pharmaceutical waste
- Medical product recalls
- Security waste requiring total destruction (such as police uniforms, or confidential data)
I own property adjacent to this property. What will I see?
You will see a secured facility with a six-foot chain link fence and electric gate.
You will see semi-trailers and employee vehicles parked in the yard. All waste activities will be conducted inside the building. There will NEVER be waste visible to the public.
You will also see also see two stacks above the building. There will be visible heat (white steam) coming from one stack in the winter.
How will this facility be different from other incinerators?
We researched many manufacturers of incinerators prior to selecting Addfield Environmental Systems. This company holds many awards and are world leaders in incineration technology. They specialize in a wide range of incinerator types and have extensive knowledge in the area.
This will be a smart incinerator, and will have many automatic safety features built into it. The combustion process is computer-controlled, based on monitors located throughout the combustion chambers and the flue gas treatment system.
It will be energy efficient and clean burning for reduced emissions. The facility will be purpose-built for the kinds of waste G-M Pearson will be handling. It will be designed with modern environmental standards in mind, to meet current and expected future regulator requirements.
Biomedical Waste Examples
Types of Industrial and Oil Field Waste
- Oil Filters
- Air Filters
- Dirty Rags
- Pipe Caps
- Noxious Weeds
- Contaminated Material
- Product Recall
- Confidential Records
- Police Uniforms
- Military Food Rations
- Out of Spec Products
If this includes human components, are there any increased emission issues?
As discussed above, the definition of bio-medical waste includes pathological (anatomical) waste. There are no extraordinary emissions associated with incineration of body tissue.
What were the specific reasons the Ryley and Beiseker projects were turned down?
The Ryley project was technically turned down due to concerns over water requirements. The Beiseker Village Council did not provide a reason. In practice in both communities, a group of residents with significant influence in the community ran a campaign opposing the incinerator and ultimately the councils turned the projects down.
What kind and how much water do you need to access?
Water requirements are 1.9 cubic meters to 2 cubic meters an hour for flue gas quenching. A portion of this needs to be potable water, as it is utilized for washing of containers prior to being used for quenching. The remainder can be storm water or treated waste water.
You had mentioned that the technology used on this site is new (developed in Europe). Can you provide us with some information regarding where it is being used, and any environmental concerns that currently exist with operating plants?
Click here to review information provided by the manufacturer. One is an example of a biomedical waste incinerator being constructed today in urban environment. While smaller in size than the proposed incinerator and with a different combustion chamber design, the emission abatement system is a similar design. The other incinerator is provided as an example of a long running design that has met design basis and emission standards of the region for twenty years. While there are some other conclusions that can be drawn from the information provided, we would caution doing so as there are differences in scale and accessories (ex. heat recovery vs quenching) that cause some numbers to differ over proposed design.
There are many articles regarding the shutdown of the Wainwright plant in 2015. What prompted this shutdown? Was it a result of the monitoring from AEP? Was it self-reported?
Relative to the 2015 closure, this was a decision by the owner of incinerator (Wainwright), not AEP. The incinerator failed a number of emission tests (which were self-reported), and while these were mitigated and the incinerator passed subsequent tests, the risk of failing a test remained. This drove the decision to shut down the incinerator.
Please explain the fire at Wainwright.
The town of Wainwright had operated an incinerator commissioned in the early 1990’s as part of their municipal waste system. G-M Pearson was contracted to operate this facility in 1997. The incinerator had a permit to incinerate non-hazardous waste including industrial, oil field, bio-medical as well as municipal. The facility was not equipped, nor intended, to handle hazardous waste.
In 2000, a fire occurred when some hazardous waste (lacquered sawdust) was mixed with non-hazardous materials. No one was injured, but significant damage occurred to the facility. Repairs were made and the incinerator continued to operate without a similar incident for fifteen years.
A lawsuit was filed and it was determined the broker that arranged for the transportation of the waste was responsible for incorrectly sending the hazardous materials to the Wainwright facility, and providing incorrect documentation to G-M Pearson.
A judge ruled that G-M Pearson had met its regulatory and contractual responsibilities by requiring the documentation, and that the regulations allowed the incinerator operator to rely on the work of qualified transporters, brokers and generators of waste. The court found that G-M Pearson went beyond the requirements of the regulation by inspecting waste prior to accepting the first load, and by taking samples of materials for examination.
Please explain emission violations that occurred at Wainwright.
The Wainwright incinerator exceeded emission standards in instances in late 2010 and 2011. The instances were largely due to:
- Inappropriate material being placed in the waste stream;
Periods when GM Pearson was implementing modifications to the emission control system in order to meet reduced emission regulation limits.
- Periods when GM Pearson was implementing modifications to the emission control system in order to meet reduced emission regulation limits.
Further modifications to the emission controls allowed the incinerator to meet emission limits, and the incinerator operated until 2015 when another emission violation occurred. Concerns over the age of equipment and the ability to prevent further emission violations led to a decision by the owner of the facility to shut down the incinerator.
Alberta Environment and Parks (AEP) can take a range of actions where there is a contravention of a regulation. These range from warnings, penalties and suspension of operations. AEP utilizes a process of assessing severity of violation and impact of violation to determine appropriate action. In this instance, the incinerator was allowed to continue to operate while further modifications were being made, and a penalty was levied.
In accessing its penalty in 2012, AEP considered the following:
- In 2007, AEP added a requirement to accumulate and submit an annual summary report of previously submitted monthly reports. G-M Pearson was aware of change but failed to add new reporting requirement. AEP deemed this a minor violation with minor impact as the information was provided to AEP throughout the year.
- AEP assessed each emission violation and applied a penalty against each instance.
A total penalty of $13,500 was assessed, and subsequently reduced to $12,500 as AEP took into consideration that G-M Pearson had engaged a third party expert on equipment selection to make the incinerator compliant with regulations.
No penalty was assessed in 2015.
In 2007, Provincial regulators strengthened emission standards in Alberta. Other emitters in Alberta negotiated grandfather clauses with the Province which set higher limits than 2007 limits. The owner of the incinerator and GM Pearson accepted the new limits and made the necessary investments to upgrade its own abatement systems. G-M Pearson would not have been in violation of emission limits if it had pursued grandfather limits, based on limits negotiated by other emitters.
What is G-M Pearson going to do to prevent Wainwright incidents occurring with proposed incinerator?
There are a number of learnings from Wainwright with respect to the design and operation of the facility that can be applied to the new plant.
With respect to operations, the plant will have a dedicated operations manager and staff with the experience and training required to safely operate the facility. The senior management of G-M Pearson bring significant experience in design of the facility, equipment selection, regulatory and institutional knowledge. Their role will be to support the onsite staff and ensure they are conforming to regulatory requirements. G-M Pearson has also built up relationships with a number of companies with expertise in waste identification and classification, emission monitoring, and human health risk assessment that it utilizes to support it’s operating units.
With respect to meeting emission regulations by design, G-M Pearson undertook significant effort to modify and operate the Wainwright incinerator to meet reduced emission limits while working with a 25 year old design. The proposed incinerator, on the other hand, is a state-of-the-art design combining proven technologies with integrated monitoring and control systems. For some flue gas components, this allows the control system to adjust operating parameters to maintain emissions within a preset range.
With respect to ensuring hazardous waste does not get sent to the facility, G-M Pearson requires a Waste Acceptance Form (WAF) for all waste streams processed at the facility. The form and a review process have been developed utilizing a firm with expertise in identification and classification of waste. The form requires generator or broker to identify materials, source of waste, identify testing that has been completed if any, and confirm it is non-hazardous and thus suitable for incineration. The proposed facility will employ a supervisor qualified to review this form work. In some cases, the review may prompt additional testing or rejection of waste should we believe there is reasonable potential of mixing hazardous waste and non-hazardous waste.
With respect to bio-medical waste, we can’t completely eliminate the possibility that someone outside of our operation places an item in a container intended for incineration that should not be incinerated and which results in an emission violation. However, Alberta’s hospitals have rigorous training and inspection programs to reduce this risk. As well, G-M Pearson and other transporters of biomedical waste work with large generators and smaller generators of bio-medical to educate and assist them on inspection programs to reduce this risk.
Other design lessons learned from Wainwright for fire risk reduction include the elimination of tipping floor in order to facilitate direct loading from trailer to incinerator with no storage of waste in the building.
We believe these measures will allow the proposed incinerator to be operated safely and within reasonable risk level to the community.
Issue of truck noise (back up alarm)
Deliveries will occur during normal business hours. G-M Pearson vehicles do not have back up alarms, as they are required to operate in areas with noise restrictions. Our drivers do not utilize compression release engine brakes within the community. There will be some instances where third party trucking firms utilize back up alarms, and there will likely be back up alarms on construction equipment used during construction of the facility.
Who does provincial environmental studies—and who pays for the studies?
The studies required to support an application for approval under the Alberta Environmental Protection and Enhancement Act will be conducted by specialists retained and paid for by G-M Pearson. These study reports are reviewed by Alberta Environment and Parks and their referral agencies (including Alberta Health) to confirm whether provincial requirements have been met.
What happens if municipal water supply is affected.
The incinerator facility will have sufficient storage of water, and can draw on a back-up electrical generator to operate for a period of time until we shutdown safely in the event power and water supply are interrupted.
What assurances can you give us that the “smart” system used in the incinerator is fool proof?
The incinerator utilizes a program logic controller (PLC) to monitor and control the operation of the incinerator. A human operator also monitors the operation of the incinerator, and can manually shutdown operation of the incinerator.
The manufacturer programs the PLC at the factory. As with all PLC’s used to monitor and control a machine, the PLC for the incinerator will have a number of fail-safe features including alarms, and ability to stop feeding material into the machine. The human operator is there to monitor and ensure the incinerator is operating within proper parameters and ensure the machine is shutdown safely if a component malfunctions, including failure of the PLC itself.
What assurances can you provide that emissions will be monitored to ensure community safety?
The Alberta Environmental Protection and Enhancement Act approval will include strict requirements for the monitoring of emissions from the facility, including continuous monitoring of key safety parameters. The results of this monitoring will be provided to Alberta Environment and Parks, and will be available to the public.
How much Co2 would the process emit – range or average?
When operating at capacity, the incinerator will produce approximately 2,000 kgs/hour.
Explain how a flue gas abatement process works.
The incinerator flue gas abatement equipment consists of:
- Stage 2
- Quench Tower
- Lime slurry
- Activated Carbon Feeder
Stage 2 is a vertical tube lined with refractory to protect the metal. In stage 2 all VOC’s (Volatile Organic Compounds) and dioxins and furans created from the burning of solid waste in stage 1 (rotary chamber) are thoroughly incinerated A natural gas burner keeps the temperature over 1000 Deg C at all times. An oxygen monitor is placed at the exit of stage 2 and controls an air fan so that we maintain 6% oxygen levels in stage 2.
The Quench tower consists of a vessel made of Hastelloy with spray nozzles. Water is injected into the Quench tower to quickly cool the flue gas from to 1000 deg C to approximately 400 deg C. The main purpose of the quench tower is to cool the flue gas to a temperature the baghouse can handle.
Lime slurry is a powdered lime mixed in a large tank with water and sprayed into a vessel after the quench tower. Acid gasses formed from the burning of plastics and other material are absorbed by the lime water and neutralized. The spray pumps are variable speed and the volume can be increased or decreased depending on the quantity of SO2 detected by the monitors. The exit temperatures from the lime slurry tower are <150 deg.C. The lime slurry tower is designed to stop any chance of dioxins/furans from reforming after stage 2, during the Deacon Window (between 400-200 deg.C) As such design of the tower is to rapidly cool temperatures during this period of thermal change.
Powdered activated carbon will be added to the flue gas stream after the lime slurry. It is designed to absorb heavy metals that maybe present in the flue gas entrails.
The baghouse consists of a series of filter bags that capture particulates, spent sorbent (lime, activated carbon) and fly ash prior to the flue gas entering the exhaust stack. The baghouse is divided up into sections so that a portion of the baghouse filters can be cleaned while the incinerator remains in operation. Recovered material is tested prior to being sent to appropriate landfill.
Describe the Emergency Response Plan? Do we need special equipment/training to put out a fire?
We will work with experts to develop a number of response plans and supply information and assist community response teams as requested. Through that process, any specialized equipment can be identified by the relevant authorities.
Is there going to be a waste transfer site and wash bay at the plant? If so, where and what would that look like?
The wash facility is incorporated into the footprint of the plant. It will consist of an industrial washing machine(s) similar to those found in a large institutional kitchen with infeed and outfeed conveyor. Reusable containers are washed prior to being loaded into trailers and sent back to medical facilities. There is no separate transfer facility. The transfer site reference is to enable waste containers to be sorted and transferred to outgoing trailers in the event incinerator is down for maintenance. Transfer reference also provides for provision to store small quantities of waste that the facility is not equipped to process, but collects as part of its scheduled pick up of bio-medical waste (ex. extracted amalgam fillings).
Does this type of plant let off a smell?
No, all organic waste is transported and stored in refrigerated trailers. Organics are completely incinerated, thus eliminating any smell from flue stack.